A conveyancing firm’s AML policy may explain how to verify a client’s identity but leave staff without clear instructions for handling unusual transactions, third-party checks or changes in technology. Those omissions matter because property transactions regularly involve changing funding arrangements, multiple participants and pressure to meet exchange and completion dates.
The SRA’s October 2026 material on anti-money laundering policies, controls and procedures highlights missing mandatory coverage alongside gaps between written requirements and practice.
This wider concern is consistent with Lexsure’s findings during the independent AML audits it has carried out over the last 12 months. Written procedures, risk assessments and the evidence on individual files do not always tell the same story.
For conveyancing firms, a useful starting question is: does the AML documentation explain what staff should do when a transaction moves beyond straightforward identification checks?
Review the instructions, not just the contents page
The SRA’s guidance on AML policies, controls and procedures explains the required coverage and its connection with the firm-wide risk assessment.
A heading in a policy does not establish that the subject has been addressed adequately. Staff need instructions that explain the enquiries to make, the evidence to consider, the decisions to record and the circumstances requiring escalation.
The following six areas provide a practical structure for reviewing your conveyancing procedures. They are suggested review priorities, rather than an exhaustive compliance checklist or a reproduction of the SRA’s exact list of omissions.
1. Unusual transactions and unclear commercial explanations
Does the policy help a conveyancer investigate a transaction that does not make obvious commercial sense?
For example, a property may be changing hands repeatedly, the proposed ownership may differ from the apparent source of funding, or the client may offer an unclear explanation for a complex arrangement.
These features do not automatically establish money laundering. They should prompt an appropriate assessment of the circumstances.
Check whether your procedures explain:
- Which transaction features require further enquiries.
- Who reviews explanations that do not fit the available evidence.
- Where the enquiries and conclusions should be recorded.
- When staff must escalate concerns to the MLRO.
A general instruction to “remain vigilant” is unlikely to answer those practical questions.
2. Reliance on checks undertaken elsewhere
Conveyancing clients may arrive through estate agents, mortgage brokers, other solicitors or professional introducers. They may also have completed an electronic identity check before instructing the firm.
The AML procedures should distinguish formal reliance from outsourcing, electronic verification and informal assurances that someone else has checked the client.
Staff should understand the firm’s permitted approach, who can authorise an arrangement and what information must be available. A referral from another professional should not be treated as an automatic answer to the firm’s own due diligence obligations.
If formal reliance is not permitted by the firm, say so clearly and explain the checks that staff must undertake instead.
3. New technology and digital onboarding
A new onboarding platform can change the information collected, the alerts presented to staff and the evidence retained on the matter.
Check whether the AML procedures identify who assesses the risks before a new system or business practice is introduced.
For a conveyancing team, practical questions include:
- What does the electronic result establish, and what remains for the conveyancer to assess?
- Who reviews alerts, exceptions or incomplete results?
- Can staff explain why they accepted the result?
- Can supervisors retrieve the underlying evidence?
- What happens if the technology or service becomes unavailable?
The decision to purchase software should be accompanied by a decision about how it will operate within the firm’s AML procedures.
4. Proliferation financing procedures
A reference to proliferation financing in the firm-wide risk assessment should lead to consideration of the procedures needed to address the firm’s identified exposure.
Check whether the documentation gives staff usable instructions for recognising relevant concerns, making further enquiries and escalating them.
The assessment should reflect the firm’s actual clients, services, ownership structures, jurisdictions and transactions. A definition included in the manual may explain the concept without explaining the required response.
Where sanctions controls form part of that response, check that the documents are consistent. Firms reviewing their arrangements can consider the dedicated Sanctions Policy available from POLICYmonitor.
5. Retaining and retrieving AML evidence
Conveyancing evidence may be spread across emails, case-management systems, electronic verification platforms and separate compliance records.
A statement that the firm retains AML records should be supported by instructions explaining what is kept, where it is stored, who can access it and how applicable retention and deletion requirements are managed.
Consider what happens when a fee earner leaves, a matter transfers between offices or a subscription to an external platform ends.
Could another reviewer reconstruct the enquiries undertaken and the reasoning behind the decision to proceed?
Our article on the AML evidence chain explains why the firm-wide assessment, procedures and individual matter records need to connect.
6. Monitoring compliance and communicating amendments
Your review process should examine the quality of the investigation as well as the presence of documents. Our guide to testing source of funds during internal AML file reviews explains the questions to ask and how to record actionable findings.
Does the documentation explain how the firm checks that its AML requirements are being followed?
A review process should identify who selects files, what the reviewer examines, how findings reach management and what happens when weaknesses recur.
It should also explain how amendments are approved and communicated. Saving an updated document to a shared drive does not, by itself, demonstrate that affected staff know what has changed.
For example, a revised procedure for third-party funding may require a change to the onboarding questionnaire, a new approval step and a briefing for the accounts team as well as the conveyancers.
Record the changes, their implementation and the steps taken to communicate them.
What Lexsure’s independent AML audits reveal
Lexsure’s audits have identified missing or ineffective client and matter risk assessments, unsupported risk ratings, inadequate evidence of source-of-funds scrutiny and retrospective assessments that do not demonstrate how risk informed earlier decisions.
Those findings illustrate why a documentation review and a review of implementation should work together. An omission may leave staff without instructions. An implementation failure may arise even where the written procedure is adequate.
Our guide to what independent AML audit file testing should reveal considers how an auditor can examine that distinction.
Turn the review into specific amendments
For each gap identified, record the missing instruction, the document requiring amendment and the person responsible. Check whether the provision exists elsewhere before creating overlapping or contradictory wording.
Firms developing or replacing documentation can browse the AML policies and procedures available from POLICYmonitor. Templates need to be selected and adapted to the firm’s actual work, risks and systems.
For continuing support, Lexsure’s AML Policy Update Service provides suggested wording for firms to consider. Our October 2026 AML policy update article discusses areas for review.
After making an amendment, consider whether forms, workflows, supervision or training also need to change. Then check whether the revised approach works on subsequent matters.
Independent review can test completeness and effectiveness
An independent AML audit can examine the firm’s documentation alongside client files and staff understanding, helping distinguish missing procedures from failures to apply existing ones.
Regulation 21 requires an independent audit function where appropriate to the size and nature of the business. It does not impose a universal requirement for every firm to purchase an annual external audit.
The useful outcome is an evidenced account of what needs to improve, who will address it and how implementation will be monitored.
What is missing from your conveyancing AML procedures?
Lexsure’s independent AML audits examine policies, risk assessments, client files and staff understanding to identify omissions and weaknesses in implementation.
Discuss an audit appropriate to your firm’s size, conveyancing work and risk exposure.